Privacy Policy

PRIVACY POLICY

Mills Brands Pty Ltd (trading as EDISONS and its subsidiaries recognise that your personal information is important to you and that you are concerned with its collection, use and disclosure. In the information below, the terms "Edisons", "we", "us" and "our" refer to Mills Brands Pty Ltd (ABN 45 117 885 828) and its subsidiaries.

THIS POLICY CONTAINS INFORMATION ABOUT:

The Edisons business model.
Your consent to this policy.
Dealing with Edisons anonymously.
The purposes for which Edisons collects, holds, uses and discloses personal information.
The types of personal information that Edisons collects.
How Edisons collects, holds, uses and discloses personal information.
How you may access the personal information that Edisons holds about you, and how you may seek correction of that personal information.
How you may complain about a breach of the Australian Privacy Principles by Edisons and how Edisons will deal with such a complaint.
Additional information.

Appendix A to this policy contains further information which Edisons is required to disclose under the Privacy Act 1988 (Cth) to individuals who apply for credit from a third party credit provider (such as Klarna, Zip Pay, Zip Money, Afterpay, Latitude Pay, PayPal) using Edisons websites or stores.

THE EDISONS BUSINESS MODEL:

To allow us to offer you lower prices on comparable products, or more features on comparably priced products sold by other retailers, we use the following model to provide our services.

We advertise products and promotions using the Internet, email and SMS. The sale of those products is handled on the Internet, with sales recorded under an individual account for each buyer allowing our team to identify & offer support to the buyer. Payment is arranged online before being evaluated by a fraud prevention service, before the products are dispatched or picked up from a warehousing location. We handle all customer service throughout this process online or over a recorded phone system. Subsequent marketing contact to alert you of additional products or promotions you may be interested in is carried out. The subsequent marketing contact, and the other points in our business model, reduce our average costs in selling each product. This in turn allows you to purchase your initial, and/or subsequent products at a lower price than would otherwise be offered by us to you.

We handle a minor proportion of our activities outside this model on a case by case basis, however the only services we offer you are in line with our business model outlined above, with the exception of your right to opt-out from future marketing contact by us.

YOUR CONSENT TO THIS POLICY

By using our services or interacting with us, you agree to this Privacy Policy and consent to the collection and use of information by us in accordance with this Privacy Policy. Please note that we reserve our right to amend, remove or vary this policy from time to time without notice. You should check this page regularly to take notice of any changes we may have made to this policy.

DEALING WITH EDISONS ANONYMOUSLY:

When you choose to deal with Edisons, we will ask you to provide personal information because it is required by law or our policies to do so, or because it would be impracticable to deal with you anonymously. These circumstances include where you order goods online (including when you pick up such goods from one of our warehousing locations), where you purchase an extended warranty on a product or accidental damage insurance, where you apply to purchase goods on finance, where you pay for goods requiring us to match your payment to the specific account related to the goods that you purchased, where you return goods for repair, where you purchase goods to be delivered, collect goods from one of our locations, where you enter one of our competitions, when you submit a request, enquiry, complaint, consumer guarantee or warranty claim and when you pre-order goods.

You have the option of using a pseudonym when dealing with us so as not to identify yourself fully to us. Please bear in mind, however, that we will be unable to provide certain services to you unless you disclose your correct identity.

If you are a candidate for employment you must provide personal information which is in all respects true, accurate and up to date and is not, in any respect, misleading, deceptive or inaccurate or likely to be misleading or deceptive.

WHY DOES EDISONS COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?

Edisons collects, holds, uses and discloses personal information for a number of purposes connected with our business operations, which include:

providing you with products and/or services you have ordered/purchased.
reducing the likelihood another party is given products or services you have paid for.
allowing payments you make to be assigned to your account, or the specific goods/services you are purchasing from us.
dealing with requests, enquiries, complaints, consumer guarantee or warranty claims, and other customer care related activities.
marketing products and services and providing advice on products.
developing and improving our products and services.
in connection with our loyalty or reward programmes and competitions.
the operation and administration of accounts or subscriptions that you have with us.
payment processing.
processing a refund or exchange of a product.
processing cash-back or prize claims.
handling gift vouchers and discount codes.
carrying out certain checks (for example, for our fraud or theft prevention processes, if you wish to open an account with us, obtain credit from us, collect goods from our warehouse, or pick-up goods that have been ordered online).
interacting with companies or organisations with whom Edisons has a business relationship (where you work for, or otherwise represent, such an organisation).
reconciling payments due to Edisons from suppliers in relation to goods or services provided to you by those suppliers.
purposes relating to any third party acquisition or potential acquisition of an interest in Edisons or its assets.
verification of claims of product suitability promised before purchase by Edisons team members.
verification of a claim of incorrect information being given by one of our team members, allowing the best possible resolution of an inquiry, dispute or complaint.
complying with our obligations under agreements with third parties (for example, under our arrangements with consumer finance or payment providers).
carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.

We may also use and disclose your personal information for other purposes related to those described above which would be reasonably expected by you.

Documents (including hard copy documents and electronic documents such as emails) which coincidentally contain personal information will also be retained in accordance with our normal document retention practices for accounting, legal and business purposes.

Generally, you have no obligation to provide any personal information requested by us. However, if you choose not to do so where we require this information, we may not be able to provide you with the goods and services that you want or deal with a request, enquiry or complaint that you have.

WHAT PERSONAL INFORMATION DOES Edisons COLLECT?

The kinds of personal information we collect or which we may hold about you may include:

your name.
your address.
your date of birth, gender and occupation.
your telephone number(s).
your email address.
payment information.
financial information such as your bank account details.
transaction information.
your user name and password.
details about your earnings (if you are buying products using a finance plan).
information contained on identification documents (such as driving licences) and, in some specific cases, copies of such identification documents, where we require these to verify your identity.
information on how you use our products and services.
your Internet Protocol ("IP") address, server address, domain name and information on your browsing activity when visiting one of our websites.
the date and time you access our sites.
the internet address of the website from which you linked directly to our sites.
any other information you may provide to us from time to time.
your user name for platforms, websites or services on which we sell our products, or social networking sites that you use, to refer to, or in conjunction with, our goods and services and personal preferences regarding products and services.
CCTV images of you whilst you visit our warehouse.

HOW DOES EDISONS COLLECT AND HOLD YOUR PERSONAL INFORMATION?

We collect personal information in a number of ways including:

when you order goods or services from us.
when you order goods or services that are supplied by us from a seller other than ourselves.
when you create an account with us prior to purchasing goods or services.
when you collect goods that you have ordered from us.
when you set up an account with us.
when you purchase certain products or extended warranties from us.
when you buy goods on lay-by.
when you request for a refund or exchange of a product.
when you subscribe to our catalogues or mailing lists.
when you subscribe to our subscription service.
when you enter competitions or promotions that we run.
when you provide us your details for customer care purposes.
when you browse one of our websites (further information is set out later in this Privacy Policy).
when you submit an enquiry using one of our websites.
when you complete surveys or provide online feedback or product reviews.
when you publicly comment about us on social media sites (for example so that we can answer questions about our products).
through the closed circuit video cameras located in our locations, when you visit one of our locations.
through recording of phone calls, when you call us (disclosure of recording is given during the call).

Generally, Edisons will collect your personal information directly from you, or from the website, company or service you used when purchasing or paying for one of our products/services.

However, Edisons also holds information, collected incidentally, concerning individuals who work for companies or organisations that have a business relationship with Edisons. Additionally, if you apply for a job with Edisons, we may collect personal information about you from any third parties that you nominate as your referees in your application.

Edisons holds personal information in a number of ways, including:

as part of customer records, product sale records, and other electronic documents on which personal information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business.
by securely storing hard copy documents on which personal information is contained, at our various premises and using third party document management and archiving services.

MARKETING

We may use your personal information that we have collected to promote and market products and services to you, including through methods such as email and SMS. We will not use your personal information for marketing purposes where you have opted out of receiving such communications.

MARKETING - HOW TO UNSUBSCRIBE

To opt-out of receiving Edisons marketing materials, you are free to unsubscribe at any time.

Emails: Every marketing email includes a link that presents unsubscribe instructions clearly, or includes those instructions directly in the email. Following these clear instructions removes the email address you nominate from receiving Edisons marketing messages.

SMS: Every marketing SMS includes a link that presents unsubscribe instructions clearly, or includes those instructions directly in the SMS. Following these clear instructions removes the phone number you nominate from receiving Edisons marketing messages.

Alternative: You may submit a Privacy Enquiry to opt-out from our marketing database. Simply specify the exact email address or mobile number you wish to unsubscribe from our marketing communications within your Privacy Enquiry. The Privacy Enquiry Form is at the bottom of this page. Please note it may take up to 5 business days to remove your email from all marketing communications.

SHARING YOUR PERSONAL INFORMATION

Edisons may disclose or receive personal information or documents about you, including to/from:

organisations that provide services to us in connection with our business, including customer support, payment processing, administration, archival, data storage, hosting, research, mail and delivery, installation, distribution, logistics, marketing, auditing, share registry, consulting, financial and legal advisory, banking, debt collection, security or technical services and the operation ofEdisons websites. In some cases these service providers may collect your personal information on our behalf.
manufacturers and distributors of goods.
if you purchase goods supplied by Edisons, the seller of the goods.
if you return goods to Edisons to be repaired, third parties including our repairs system administrator, the manufacturer of the goods and authorised repairers.
law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities.
parties involved in any third party acquisition or potential acquisition of an interest in Edisons or its assets.
our insurers and insurance brokers.
if goods you purchase from Edisons are subject to a product recall, the manufacturer or distributor of those goods.
to other third parties where you have consented to the disclosure of information to these third parties.

Additionally, if you return goods to us on which or with which personal information is stored for refund, repair or replacement, (for example, electronic fitness equipment) and do not delete that personal information, Edisons may send the goods to a repairer or other party. By returning such goods to Edisons without removing your personal information, you consent to Edisons disclosing any personal information contained on the goods to the recipients of the goods.

Third parties we use to help us detect and prevent fraudulent transactions are the companies Kount, Riskified and Forter. These companies will use your personal data in accordance with and for the purposes set out in their privacy policies (available at https://kount.com/legal/privacy-policy/ https://www.riskified.com/privacy/ and https://www.forter.com/services-privacy-policy/). When you submit an order on the Edisons website, one of these services will use the personal information submitted as part of your order to provide us with a fraud analysis indicating whether or not your order is, in their assessment, a fraudulent transaction. They will also use this personal information in accordance with their Privacy Policy above, including to provide similar fraud analysis services to their other clients, if you place an order on a website of one of their other clients. By reviewing the data of your activities across the merchant websites to which it provides fraud analysis services, they are able to detect fraudulent activity with a much higher degree of accuracy.

DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS

Edisons is likely to disclose the personal information that it collects and holds about you to third parties who are not in Australia (such as third parties who are located in the Philippines, United States of America, Singapore, the United Kingdom, Holland, Sweded, Israel and New Zealand) for one or more the purposes set out in this policy e.g. to provide you the goods/services you have purchased. Some of the jurisdictions in which these third parties are located may have less protective privacy and data protections laws than Australia.

PERSONAL INFORMATION COLLECTED ON BEHALF OF OTHER PARTIES

Edisons may collect information about you on behalf of third parties. For example, information collected for finance providers such as Klarna, Zip Pay, Zip Money, Afterpay, Latitude Pay and PayPal if you wish to purchase goods on finance.

In these cases the privacy policy available on the website of the finance provider will set out how the personal information that you provide will be used by these third parties and the privacy policies of the third parties will apply. Edisons may also receive personal information or documents about you from these third parties where necessary in connection with the provision of goods or services by Edisons.

HOW WE DEAL WITH YOUR PERSONAL INFORMATION IF YOU APPLY FOR A JOB WITH US

If you apply for a job with us, you may be required to provide us with certain personal information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.

We will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, we will disclose only such information as is necessary in the circumstances.

In considering your application, we may also collect personal information about you from any third parties that you nominate as your referees in your application.

SECURITY OF YOUR PERSONAL INFORMATION

We will take reasonable steps to ensure that the personal information that we hold is stored in a secure environment protected from misuse, interference and loss and any unauthorised access, modification or disclosure.

HOW TO ACCESS, CORRECT AND UPDATE YOUR PERSONAL INFORMATION

Upon your request, Edisons will provide access to your personal information that we hold (except in certain circumstances set out in the Privacy Act 1988 (Cth)). Edisons reserves the right to charge you an administration fee of $25 for providing access to your personal information and will, of course, require some proof of your identity before providing information to you.

You may also request us to correct the personal information that Edisons holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, Edisons will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

To request access to the personal information that Edisons holds about you, or to update or correct that personal information, please submit a privacy enquiry. The Privacy Enquiry Form is at the bottom of this page.

HOW TO MAKE A COMPLAINT

If you are concerned that the way Edisons collects, holds, uses or discloses your personal information may be in breach of the Australian Privacy Principles, please send the details of your complaint to The Privacy Officer by submitting a privacy enquiry. The Privacy Enquiry Form is at the bottom of this page.

HOW EDISONS WILL HANDLE COMPLAINTS

After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:

- conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate the best possible solution/action related to your complaint.

- notify you of the results of our investigation of your complaint.

We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe.

ADDITIONAL INFORMATION FOR USERS OF OUR WEBSITES

If you visit any of our websites (the "Websites") to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes. (ii) for website administration, security and maintenance purposes. and (iii) to direct you to material on our Websites that we believe will be of interest to you.

Like many websites, our Website uses "cookies". Cookies are small text files that we transfer to your device through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes and to measure traffic and visitor behaviour, and to understand the impact of online advertising, use remarketing and audience targeting. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer usually allow cookies, but users can easily erase cookies from their devices or block all cookies. Please note that some parts of the Website may not function fully for users that disallow cookies.

We use cookies to gain statistics on which areas of our sites attract traffic. We also use cookies to improve your experience of our websites. For example, cookies allow us to recognise whether or not you are returning to our websites. In addition, like most websites, we make use of third parties who use cookies to serve ads based on past visits to our website. This may allow us to alert you to products or offers which we think you might be interested in viewing.

Our Website also uses tags, which are tiny bits of website code that allow us to measure traffic and visitor behaviour, and to understand the impact of online advertising, use remarketing and audience targeting. These tags do not collect any personally identifiable information.

We use Google Analytics Advertising Features to promote our Services. Google and other third parties collect data about traffic to this site via advertising cookies and identifiers. This enables us to display ads on other sites that are relevant to you, based on your previous visits to this site. If you would like to prevent your data from being used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout

While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we use our best efforts to ensure its security in our possession.

The Websites may contain links/ plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites.

EXEMPTIONS

Edisons sometimes handles personal information relying on exemptions under the Privacy Act 1988 (Cth), for example in relation to (i) employee records. (ii) related bodies corporate. (iii) provision of services to State or Territory authorities. and (iv) operations outside Australia relating to personal information of non-Australians.

Any permitted handling of personal information under such exemptions will take priority over this Privacy Policy to the extent of any inconsistency.

PRIVACY QUERIES

If you have any queries or concerns, further information can be obtained by contacting our Privacy Officer by submitting a privacy enquiry, or by post to The Privacy Officer, Mills Brands Pty Ltd, PO Box 356, Castle Hill, NSW 1765. The Privacy Enquiry Form is at the bottom of this page.

APPENDIX A (APA) – FURTHER INFORMATION FOR INDIVIDUALS WHO APPLY WITH US FOR CREDIT FROM A THIRD PARTY CREDIT PROVIDER

APA Point 1 - Background:

As part of our arrangements with third party credit providers (such as Klarna, Zip Pay, Zip Money, Afterpay, Latitude Pay, PayPal):

Customers may apply through us, or with our assistance, for credit provided by third party credit providers.
Edisons may assist in the processing of such applications.

This Appendix A contains certain information which Edisons is required under the Privacy Act 1988 (Cth) to disclose to individuals who make such an application. In this Appendix A, these individuals are referred to as Third Party Credit Applicants.

Unless you are a Third Party Credit Applicant, the information in this Appendix A will not be relevant to you.

APA Point 2 - What kinds of credit-related information does Edisons collect and hold about Third Party Credit Applicants?

Edisons may collect (and hold) certain personal information contained in the application documentation completed by Third Party Credit Applicants when they apply for credit from a third party credit provider, including their:

full name.
date of birth.
sex.
current address (as shown on their driver’s licence).
employer.
driver's licence number.

Edisons will also collect (and hold) certain information contained in the application completed by Third Party Credit Applicants about the credit applied for by Third Party Credit Applicants, including:

the name of the third party credit provider.
the type of credit applied for.
the day on which the credit is applied for (and entered into).
the terms and conditions of the credit applied for (including in relation to repayment).
the maximum amount of credit available under the consumer credit applied for.
the expiry date of the credit.

The information described in the preceding 2 paragraphs is collectively referred to as Application Documentation Information.

APA Point 3 - Why does Edisons collect, hold, use and disclose Application Documentation Information?

Edisons collects, holds, uses and discloses Application Documentation Information for the purposes of:

Submitting the application completed by Third Party Credit Applicants to the relevant third party credit providers.
Administering its arrangements with those third party credit providers.

Application documentation submitted by Third Party Credit Applicants (which will contain Application Documentation Information) will also be retained in accordance with our normal document retention practices for legal and business purposes.

APA Point 4 - How does Edisons hold Application Documentation Information?

Edisons holds Application Documentation Information as outlined in our Privacy Policy above.

APA Point 5 - Is Edisons likely to disclose Application Documentation Information to recipients who are not subject to Australian privacy laws?

Edisons handles Application Documentation Information in the manner outlined in our Privacy Policy above.

APA Point 6 - How to correct and update your Application Documentation Information:

You may also request us to correct the Application Documentation Information that Edisons holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, Edisons will take such steps as are reasonable in the circumstances to correct your Application Documentation Information to ensure that, having regarding to the purpose for which it is held, it is accurate, up-to-date, complete, relevant and not misleading.

To request Edisons to correct or update the Application Documentation Information that it holds about you, please send a written request to The Privacy Officer by submitting a privacy enquiry. The Privacy Enquiry Form is at the bottom of this page.

APA Point 7 - How to make a complaint:

If you are concerned that the way Edisons collects, holds, uses or discloses your Application Documentation Information may be in breach of Division 3 of Part IIIA of the Privacy Act 1988 (Cth) or the registered Credit Reporting Privacy Code, please send the details of your complaint to The Privacy Officer by submitting a privacy enquiry. The Privacy Enquiry Form is at the bottom of this page.

APA Point 8 - How Edisons will handle complaints:

Conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate the best possible solution/action related to your complaint.
Notify you of the results of our investigation of your complaint.